Iowa Department of Education May 18 - 21, 2004 Scope of Review: The U.S.

Department of Education’s (ED) Student Achievement and School Accountability Programs (SASA) team monitored the Iowa Department of Education (IDE) the week of May 18 - 21, 2004. This was a comprehensive review of the IDE's administration of Title I, Part A and B funds, as required by the Elementary and Secondary Education Act of 1965 (ESEA), as amended by the No Child Left Behind Act of 2001 (NCLB). In conducting this comprehensive review, the ED team carried out a number of major activities. In reviewing the Part A program, the ED team conducted an analysis of State assessments and State accountability system plans, review of the effectiveness of the instructional improvement and instructional support measures established by IDE to benefit local educational agencies (LEAs) and schools, and review of compliance with fiscal and administrative oversight requirements required of the State educational agency (SEA). During the onsite monitoring review, the ED team interviewed IDE personnel to determine how the SEA is meeting its NCLB requirements in each of the three monitoring areas (accountability, instructional support, and compliance with fiduciary responsibilities). The ED team visited two LEAs – the Des Moines and Waterloo School Districts. During these two LEA visits the ED team interviewed LEA and school administrative staff, visited five schools operating schoolwide programs, one school operating a targeted assistance program, two programs serving private school children, and conducted a district-wide parent meeting at each LEA. The ED team conducted conference calls to two additional LEAs (Davenport and Central Decatur) following the onsite monitoring review to confirm information gathered from the Des Moines and Waterloo School Districts and at IDE. In reviewing Part B of Title I (Even Start), the ED team examined the State request for proposals, State Even Start guidance, State indicators of program quality, and the most recent applications, local evaluations, and expenditure reports from the Even Start programs in Bettendorf and Iowa City. During the onsite review, the team visited those two local Even Start programs and interviewed administrative and instructional staff. Finally, the team interviewed the IDE’s Even Start State coordinator to confirm data collected at the two local sites and to discuss State administration issues. Previous Audit Findings: None Previous Monitoring Findings: The Department of Education team last reviewed Title I, Part A programs in December 1997 as part of a Federal integrated review initiative. IDE satisfactorily addressed all compliance issues cited in the review in April 1998. ED has not previously conducted a comprehensive review of the Even Start program in Iowa.

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Title I Monitoring Summary of Critical Monitoring Elements Monitoring Area 1: Accountability Critical element SEA has approved academic content standards for all required subjects or an approved timeline for developing them. The SEA has approved academic achievement standards and alternate academic achievement standards in required subject areas and grades or an approved timeline to create them. The SEA has approved assessments and alternate assessments in required subject areas and grades or an approved timeline to create them. The SEA has implemented all required components as identified in its accountability workbook. NCLB report card requirements are addressed separately (1.5) The SEA has published its annual report card and ensured that LEAs have published annual report cards as required. SEA indicates how funds received under Grants for State Assessments and related activities (§6111) will be or have been used to meet the 2005-06 and 2007-08 assessment requirements of NCLB. SEA ensures that LEAs meet all requirements for identifying and assessing the academic achievement of limited English proficient students.

Indicator Number Critical element 1.1 Critical element 1.2 Critical element 1.3 Critical element 1.4 Critical element 1.5 Critical element 1.6

Status Met Requirements Met Requirements Finding

Page N/A

N/A

6

Commendation

6

Finding Met requirements

6 N/A

Critical element 1.7

Met requirements

N/A

Indicator Number

Monitoring Area 2: Instructional Support Critical element

Status

Page

3

Critical element 2.1 Critical element 2.2 Critical element 2.3 Critical element 2.4 Critical element 2.5

Critical element 2.6 Critical element 2.7 Critical element 2.8

Critical element 2.9

The SEA designs and implements policies and procedures that ensure the hiring and retention of highly qualified staff. The SEA provides, or provides for, technical assistance for LEAs and schools as required. The SEA establishes a Committee of Practitioners and involves the committee in decision making as required. The SEA ensures that the LEA and schools meet parental involvement requirements. The SEA ensures that schools and LEAs are identified for improvement, corrective action, or restructuring as required and that subsequent, required steps are taken. The SEA ensures that requirements for public school choice are met. The SEA fulfills the statutory requirements for the provision of supplemental educational services (SES) are met. The SEA ensures that LEAs and schools develop schoolwide programs that use the flexibility provided to them by law to improve the academic achievement of all students in the school. The SEA ensures that LEAs and schools develop and maintain targeted assistance programs that meet all required components

Met requirements

N/A

Commendation Recommendation

7 7

Recommendation Finding Recommendation

7 7

Finding Met requirements

8 N/A

Met requirements

N/A

Met requirements

N/A

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Indicator Number Critical element 3.1 Critical element 3.2 Critical element 3.3 Critical element 3.4 Critical element 3.5 Critical element 3.6 Critical element 3.7

Monitoring Area 3: Fiduciary Critical element The SEA ensures that its component LEAs are audited annually, if required, and that all corrective actions required through this process are fully implemented. The SEA complies with the allocation, reallocation, and carryover provisions of Title I. The SEA complies with the maintenance of effort provisions of Title I. The SEA ensures that the LEA complies with the comparability provisions of Title I. The SEA ensures that LEAs provide Title I services to eligible children attending private schools. The SEA has a system for ensuring and maximizing the quality, objectivity, utility, and integrity of information disseminated by the agency. The SEA has an accounting system for administrative funds that includes (1) state administration, (2) reallocation, and (3) reservation of funds for school improvement. The SEA has a system for ensuring fair and prompt resolution of complaints. The SEA ensures that the LEA complies with the rank order procedures for the eligible school attendance areas. The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Title I program requirements. The LEA complies with the provision for submitting an annual plan to the SEA. The SEA and LEA comply with requirements regarding the reservation of administrative funds. The SEA ensures that Title I funds are used only to supplement or increase non-Federal sources used for the education of participating children and not to supplant funds from non-Federal sources.

Status Recommendation

Page 9

Met requirements Met requirements Met requirements Findings Met requirements

N/A N/A N/A 10 N/A

Met requirements

N/A

Critical element 3.8 Critical element 3.9 Critical element 3.10 Critical element 3.11 Critical element 3.12 Critical element 3.13

Finding Finding Recommendation

9 10 12

Commendation Met requirements Met requirements

12 N/A N/A

Area: Accountability

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Critical Element 1.3 – The SEA has approved assessments and alternate assessments in required subject areas and grades or an approved timeline to create them Finding: The ED team found that between 70% and 80% of Black, Hispanic, LEP and students with disabilities, on average, were being included in school and district administrations of the Iowa state tests based on data provided by the IDE. Those percentages serve as evidence that not all students are being included in test administrations as required. Citation: 20 U.S.C. 6316 §1116(b)(3)(C)(ix) requires the participation in such assessments of all students. Further Action Required: IDE must clarify its guidance to LEAs on student participation in State assessments (all students must be tested), provide technical assistance to LEAs on student participation on State tests and include a review of student participation rate data in LEA monitoring conducted by the IDE. Critical Element 1.4 – The SEA has implemented all required components as identified in its accountability workbook. Commendation: IDE has designed and implemented the Iowa Accountability website which allows access to LEAs and the SEA for data entry related to student proficiency percentages and participation rates on State assessments used for NCLB accountability. Area Education Agencies (AEAs) have read-only access to the website and can monitor compliance with various NCLB and State requirements. This is an excellent tool that has been made available in a SEA that has a wide range of dates for administering its State assessment for NCLB purposes. Critical Element 1.5 – The SEA has published its annual report card and ensured that LEAs have published annual report cards as required. Finding: The ED team found that LEA school report cards are missing the State and LEA comparisons with school performance on the other academic indicators required for NCLB accountability. Citation: 20 U.S.C. 6316 §1111(h)(2)(B)(ii)(II) requires the SEA to ensure that each school provide information on the school report cards that shows how student achievement on the statewide academic assessments and other indicators of adequate yearly progress compare to performance at the LEA and SEA levels. Further Action Required: IDE must provide guidance and technical assistance to the LEAs on reporting the LEAs’ performance on the NCLB accountability and other academic indicators as well as the State performance on the same indicators on the LEA

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report cards. IDE must monitor district compliance with this requirement to ensure that LEA report cards contain all of the information required by NCLB.

Area: Instructional Support
Critical Element 2.2 - The SEA provides, or provides for, technical assistance for LEAs and schools as required. Commendation: The Iowa Professional Development Content Network Web site, developed by the IDE, provides practitioners with easy access to high-quality research. The site offers reviews of research studies focused on specific instructional strategies and programs in both reading, mathematics, and science and encourages the use of scientifically based research. Critical Element 2.3 – The SEA establishes a Committee of Practitioners and involves the committee in decision making as required. Recommendation: The IDE’s Title I Committee of Practitioners has a roster of only five members. Since the purpose of this committee is to advise IDE in carrying out its Title I responsibilities statewide, including developing and monitoring the implementation of the State’s Title I plan, the ED team recommends that the IDE expand its active membership to create participation that is more representative of the entire State. Critical Element 2.4 - The SEA ensures that the LEA and schools meet parental involvement requirements. Recommendation: The ED team urges the IDE to review its guidance to LEAs regarding effective parental involvement to more strongly emphasize school-level involvement that engages parents in their children’s education. Although LEAs and schools appear to meet parental involvement requirements, such as written parental involvement policies and home-school compacts, they would benefit from more direction and guidance about effective parental involvement strategies that result in a positive impact on student achievement. Critical Element 2.5 – The SEA ensures that schools and LEAs are identified for improvement, corrective action, or restructuring as required and that subsequent required steps are taken. Finding: When schools do not make adequate progress for two years in a row, they are required to write, or revise, a school improvement plan. School improvement plans examined by the ED team during and after the site visit (called 2-year action plans in Iowa) do not contain all of the required elements.

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The following required elements are missing from one or more of the plans reviewed:

Specific annual measurable objectives for progress for each subgroup of students. Analyzing subgroup performance and establishing objectives to address the learning needs of subgroups that are not succeeding is especially important in schools identified for improvement. Clear delineation of the responsibilities of the LEA, including technical assistance it will provide, in helping the school to exit from school improvement. Strategies to promote effective parental involvement. These are identified in each school’s schoolwide plan, but are mentioned in only one of the school improvement plans. If the SEA or LEA chooses not to combine plan requirements into a single format, then the plan must indicate that required strategies can be found in another document Explanation of teacher mentoring activities

Citation: 20 U.S.C. 6316 §1116(b)(3) requires each school identified for school improvement to develop or revise a school plan. The school plan must include at least the ten components described in this section. Further Action Required: The IDE must clarify for its LEAs and schools the requirements of the school improvement plan. In cases where a school is both a schoolwide program school and a school identified for improvement as the result of not making adequate yearly progress (AYP) for two consecutive years, the school may create or revise a single plan, since doing so allows the school to concentrate its efforts on a single set of goals and strategies. However, if the IDE allows schools to create one plan, it must ensure that the statutory and regulatory components of school improvement plans as well as the statutory and regulatory components of schoolwide program plans are included in the document. The ED team requests a copy of the guidance offered by the SEA on this issue and one copy of a revised plan from a school identified for improvement. Recommendation: The ED team encourages the IDE to continue its efforts to consolidate and streamline planning processes and products required of schools and LEAs. To the degree possible, LEAs and schools should be allowed to author a single, strong plan that not only includes required content, but truly “drives the work” of the school and its staff. Critical Element 2.6 – The SEA ensures that requirements for public school choice are met. Finding: The ED team found that public school choice is offered in Iowa schools identified for improvement. However, documentation revealed that in the Waterloo

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school district choice was limited to only low-performing, high-poverty students. Although the LEA is required to give priority to low achieving students from low-income families, choice must be offered to all students in the school so identified. Citation: 20 U.S.C. 6316 §1116(b)(1)(E)(ii) states that the LEA shall provide all students enrolled in the school with the option to transfer to another public school served by the LEA that has not been identified for improvement. In providing students the option to transfer, the LEA shall give priority to the lowest achieving children from low-income families. Further action required: The IDE must clarify in its guidance to LEAs that all parents of children who attend a school identified for improvement, corrective action, or restructuring must be notified of their option to have their child attend another school in the LEA that is not so identified. It must also provide to ED documentation that parents in the Waterloo school district have been notified of this right.

Area: Fiduciary
Critical Element 3.1: The SEA ensures that its component LEAs are audited annually, if required, and that all corrective actions required through this process are fully implemented. Recommendation: Although the IDE has a system of receiving notices of Title I noncompliance from IDE's School Finance Section to follow up on LEA single audits, notices of Title I audit findings and questioned costs for LEAs visited by the ED team were not submitted to IDE. Since States must use such fiscal control and fund accounting procedures to ensure proper disbursement of, and accounting for, Federal funds paid to the State, the IDE should ensure that audit findings and questioned costs are resolved in a timely and appropriate manner. This would particularly benefit LEAs identified as highrisk grantees under the Single Audit Act. Procedures for resolving and tracking audit findings should also be included in the State’s Title I reference manual so IDE staff can better utilize LEA audit data to strengthen accountability. Critical Element 3.8: The SEA has a system for ensuring fair and prompt resolution of complaints. Finding: The IDE does not have a complaint policy or procedures in place for Title I issues. Citation: 20 USC 7844 § 9304(a)(3)(C) of ESEA requires States to adopt written procedures for the receipt and resolution of complaints alleging violations of law in the administration of programs. This provision is required under the general applicability of State educational agency assurances, whereby a State educational agency, in consultation with the Governor of the State, that submits a consolidated State plan or consolidated

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State application, shall have on file with the Secretary a single set of assurances, applicable to each program for which the plan or application is submitted Further Action Required: IDE must develop and have approved through its regular approval and adoption process a set of written procedures for the receipt and resolution of complaints, and provide ED with these procedures. Critical Element 3.5: The SEA ensures that LEAs provide Title I services to eligible children attending private schools; and Critical Element 3.9: The SEA ensures that the LEA complies with the rank order procedures for the eligible school attendance area. Findings: The ED team found that the LEAs it visited did not allocate Title I, Part A funds to their schools in accordance with the statute and regulations. The LEAs visited did not (1) establish an amount it uses to allocate per poor child and (2) allocate Title I funds to schools based on the number of poor children residing within the school attendance area. Rather, the districts used a “weighted budget” based on full time equivalent (FTE) teacher counts. While the FTE weighted budget takes into account the number of students on free and reduced lunches and the rank order of schools according to poverty, district documents indicate that resources were allocated based on teacher assignments rather than on the number of poor children. In addition, the LEA failed to identify the amount it allocated per poor child—a figure that is needed to determine how much is needed to provide equitable services for eligible students attending private schools. Citation: Section 1113 of the Elementary and Secondary Education Act (ESEA) (20 U.S.C.6313) and § 200.78 of the Title I regulations require that an LEA allocate Title I, Part A funds to eligible school attendance areas in rank order, based on the total number of children from low-income families in each area or school. Poverty is the only factor an LEA may use to allocate Title I funds to school attendance areas or schools. An LEA may not allocate Title I funds based on an instructional model, educational need, or teacher assignments. Further Action Required: The IDE must ensure through its monitoring process that each LEA within the State rank its school attendance areas and schools according to its poverty rates and determine its Title I allocations based on the number of poor children in accordance with section 1113 of ESEA and § 200.78 of the Title I regulations. In addition IDE must ensure that an LEA allocate an equitable amount of Title I funds for services to eligible private school children. Finding: The LEAs visited by the ED team could not provide documentation that they correctly reserved funds from their Title I, Part A allocations for required activities such

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as choice-related transportation and supplemental services, professional development, services to homeless children and children in locally operated neglected institutions. Citation: Under §200.77 of the Title I regulations an LEA must reserve funds before allocating funds to its schools to— • Provide services comparable to those provided to children in participating school attendance areas and schools to serve- Children in local institutions for neglected children; and  Eligible homeless children who do not attend participating schools, including providing educationally related support services to children in shelters and other locations where homeless children may live. • Meet the requirements for choice-related transportation and supplemental educational services in sections 1116(b)(10) and 1116(e)(6) of the Title I statute and §200.48 of the Title I regulations unless the LEA meets these requirements with non-Title I funds. The statute and regulations require that, unless a lesser amount is needed, an LEA spend an amount equal to 20 percent of its Title I, Part A allocation for this purpose. Of this amount, 5 percent must support choice-related transportation, 5 percent must support providing supplemental educational services, and the remaining 10 percent may support the costs of providing either choice-related transportation or supplemental educational services. Meet the professional development requirements of—  Section 1116(c)(7)(A)(iii) of the Title I statute and §200.52(a)(3)(iii) of the Title I regulations if the LEA has been identified for improvement. An LEA must reserve at least 10 percent of its Title I, Part A allocation for this purpose; and  Section 1119(l) of the Title I statute and §200.60 of the Title I regulations to meet the needs of teachers who are not highly qualified. An LEA must reserve an amount for this purpose that ranges from at least 5 to no more than 10 percent of its Title I, Part A allocation for school years 2002-03 and 2003-04 and at least 5 percent in subsequent years. • Meet the requirements for parent involvement. An LEA that receives more than $500,000 under Title I, Part A, subpart 2 must reserve at least 1 percent of its allocation for parental involvement activities. The LEA must distribute not less than 95 percent of the amount reserved for parent involvement to schools receiving Title I services.

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Administer Part A programs for public and private school children, conduct other authorized activities, such as preschool programs, summer school and intersession programs, additional professional development, school improvement, and coordinated services. Provide, if appropriate, services to-Children in local institutions for delinquent children. Neglected and delinquent children in community day school programs.

Provide, where appropriate under section 1113(c)(4) of the Title I statute, not more than 5 percent of its Part A allocation for financial incentives and rewards to teachers who serve students in Title I schools identified for school improvement, corrective action, and restructuring, for the purpose of attracting and retaining qualified and effective teachers.

Further Action Required: The IDE must ensure through its monitoring procedures that LEAs correctly reserve the amounts required by the Title I statute and regulations before allocating funds to their school attendance areas and schools. Critical Element 3.10: The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Title I program requirements. Recommendation: The ED team strongly recommends that the IDE develop and implement a timely and systematic process for monitoring its grantees. During the onsite review, only one LEA visited by the ED team had available a Title I monitoring report issued by IDE. The monitoring review that resulted in that report was conducted in 1999, thus the most significant areas of NCLB were not addressed. States must ensure that programs will be administered in accordance with all applicable statutes, regulations, program plans, and applications. States must adopt and use proper methods of administering Federal programs, including the correction of deficiencies in program operations that are identified through audits, monitoring, or evaluation. State monitoring policies and procedures should address the onsite review process as well as a method for correcting areas of noncompliance identified during State reviews. Data collected through the monitoring process should also inform other State activities, such as technical assistance, strategic planning, and effective school improvement strategies. Most effective monitoring plans also include a mechanism for incorporating data from single audits into the process. Critical Element 3.11: The LEA complies with the provision for submitting an annual plan to the SEA. Commendation: IDE's document, Local Educational Agency Title I Reference Manual: 2003-2004, provides detailed guidance for submitting the annual LEA plan through the

12

State’s Title I electronic Internet application system. This reference manual provides an excellent summary of Title I allocation trends and issues. Highlights of Title I requirements and Congressional policy changes over time are clearly presented, and critical issues, such as eligibility criteria, Federal allocation factors, hold harmless provisions, and counting local neglected and delinquent children are described. State contact officials and Federal and State web resource sites are also included.

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Element Number Critical element 1.1

Title I, Part B Monitoring Summary of Critical Monitoring Elements Monitoring Area 1: Accountability Description SEA complies with the subgrant award requirements. The SEA requires applicants to submit applications for subgrants with the necessary documentation. In making non-competitive continuation awards, the SEA reviews the progress of each subgrantee in meeting the objectives of the program and evaluates the program based on the indicators of program quality. The SEA refuses to award subgrant funds to an eligible entity if the agency finds that the entity has not sufficiently improved the performance of the program, as evaluated, based on the indicators of program quality. The SEA develops, based on the best available research and evaluation data, indicators of program quality for Even Start programs. The SEA uses the Indicators of Program Quality to monitor, evaluate, and improve local programs within the State. The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Even Start program requirements. The SEA ensures that projects provide for an independent local evaluation of the program that is used for program improvement.

Status Recommendation

Page 16

Critical element 1.2 Critical element 1.3

Recommendation Finding

16 16

Critical element 1.4

Finding

16

Critical element 1.5

Recommendation

16

Critical element 1.6

Met Requirements

Critical element 1.7

Recommendation

17

Critical element 1.8

Finding

17

Element

Monitoring Area 2: Instructional Support Description

Status

Page

Critical element 2.1

Critical element 2.2

Critical element 2.3

The SEA uses funds to provide technical assistance Recommendation to LEAs to improve the quality of Even Start family literacy services or comply with State indicators of program quality. Each program assisted shall include the Met requirements identification and recruitment of families most in need and serve those families. Each program shall include screening and Met requirements preparation of parents and enable those parents and children to participate fully in the activities and services provided. SEA ensures that all families receiving services participate in all four core instructional services. Each program shall be designed to accommodate the participants’ work schedule and other responsibilities, including the provision of support services, when those services are unavailable from other sources. Each program shall include high-quality, intensive instructional programs that promote adult literacy and empower parents to support the educational growth of their children, and in preparation of children for success in regular school programs. Each instructional staff of the program hired after January 8, 2002 of whose salary is paid in whole or in part with Even Start funds, meets the Even Start staff qualifications. By December 21, 2004, a majority of the individuals providing academic instruction shall have obtained an associate’s, bachelor’s or graduate degree in a field related to early childhood education, elementary school or secondary school education, or adult education. Met requirements Commendation

17

N/A

N/A

Critical element 2.4 Critical element 2.5

N/A 17

Critical element 2.6

Met requirements

N/A

Critical element 2.7

Met requirements

N/A

Critical element 2.8

Met requirements

N/A

Critical element 2.9

By December 21, 2004, if applicable, a majority Met requirements of the individuals providing academic instruction shall meet the qualifications established by the State for early childhood education, elementary or secondary education, or adult education provided as part of an Even Start program or another family literacy program.

N/A

Critical element 2.10

Critical element 2.11

Critical element 2.12

Critical element 2.13

Critical element 2.14

Critical element 2.15

Critical element 2.16

By December 21, 2004, the person responsible for administration of family literacy services has received training in the operation of a family literacy program. By December 21, 2004, paraprofessionals who provide support for academic instruction will have a secondary school diploma or its recognized equivalent. The local programs shall include special training of staff, including child-care workers, to develop the necessary skills to work with parents and young children. The local programs shall provide and monitor integrated instructional services to participating parents and children through home-based programs. The local programs shall operate on a year-round basis, including the provisions of some program services, including instructional and enrichment services, during the summer months. The local program shall be coordinated with other relevant programs under the Adult Education and Family Literacy Act, the Individuals with Disabilities Act, and Title I of the Workforce Investment Act of 1988 and the Head Start program, volunteer literacy programs, and other relevant programs. The local programs shall use instructional programs based on scientifically based reading research for children and adults. The local program shall encourage participating families to attend regularly and to remain in the program a sufficient time to meet their program goals. The local programs shall use reading-readiness activities for preschool children based on scientifically based reading research. The local program shall, if applicable, promote the continuity of family literacy to ensure that individuals retain and improve their educational outcomes.

Met requirements

N/A

Met requirements

N/A

Met requirements

N/A

Commendation

18

Met requirements

N/A

Met requirements

N/A

Finding

18

Critical element 2.17

Commendation

18

Critical element 2.18

Finding

18

Critical element 2.19

Met requirements

N/A

Element Number Critical element 3.1

Monitoring Area 3: SEA Fiduciary responsibilities Description Status The SEA complies with the allocation requirements Met requirements for State administration and technical assistance, and award of subgrants. The SEA ensures that subgrantees comply with statutory and regulatory requirements on uses of funds and matching. The SEA complies with the cross-cutting maintenance of effort provisions. The SEA ensures timely and meaningful consultation with private school officials on how to provide Even Start services and benefits to eligible elementary school students attending non-public schools and their teachers or other personnel, and local programs provide an appropriate amount of those services and benefits through an eligible provider. The SEA has a system for ensuring fair and prompt resolution of complaints. Met requirements

Page N/A

Critical element 3.2

N/A

Critical element 3.3

Met requirements

N/A

Critical element 3.4

Finding

19

Critical element 3.5

Met requirements

N/A

Title I Part B – Even Start Area: Accountability
Critical Elements 1.1 and 1.2–Complying with Subgrant Award Requirements Recommendation: In order to fund projects that more strongly meet the purposes of the Even Start program, ED recommends that the IDE increase the focus of the application package on the quality of the educational services that will be delivered to families. Critical Elements 1.3 and 1.4 – Use of State Indicators for Making Non-Competitive Continuation Awards and Refusal of Award to Grantees not making Sufficient Progress Finding: During discussions with IDE staff, the ED team learned that the Statedeveloped indicators of program quality are not being fully used for their intended purposes. IDE does not consider all of the required indicators of program quality when determining if subgrantees are making sufficient progress in order to make continuation awards. In addition to not using all the required indicators of quality, IDE does not evaluate programs against the program objectives outlined in the original applications when making continuation awards. Citation: 20 U.S.C. 6381g(b)(3), Section 1238(b)(3) of ESEA, requires States to use their indicators of program quality and to review the progress of each program in meeting its program objectives to determine if projects are making sufficient progress and to make decisions about continuation awards. 20 U.S.C 6381g(b)(4), Section 1238(b)(4) of ESEA, allows States to refuse to award subgrant funds to an eligible entity if the agency finds that the eligible entity has not sufficiently improved the performance of the program, as evaluated, based on the indicators of program quality developed by IDE under Section 1240. Further Action Required: The SEA must ensure that the indicators of program quality required in the statute are used by IDE to make continuation award decisions. Critical Element 1.5 – Developing Indicators of Program Quality Recommendation: ED recommends that the SEA strengthen the data collection process and the measures used to determine progress against the Even Start indicators of program quality. ED also recommends that the IDE strengthen the measures used to determine progress for children in the development of language and literacy skills enrolled in the early childhood education component. Currently children’s movement from one level to another level on an observational assessment determines progress. It is unclear how progress from one level to the next level on this measure is based on scientifically based reading research or predictive of children's later achievement on State content standards

or State achievement standards. ED recommends that the SEA choose a valid and reliable measure for each age group for use in determining progress against this required indicator and that the measure(s) be based on scientifically based reading research. The measures should be designed to assess reliably those language and early literacy skills that are linked by scientifically based reading research to later reading outcomes. Critical Element 1.7 – Monitoring of Projects to ensure compliance with Even Start program requirements Recommendation: IDE should develop a monitoring plan to ensure all Even Start programs are monitored consistently and develop a monitoring instrument that includes all required indicators and the 15 program elements of Even Start. Critical Element 1.8 – Independent Local Evaluation Finding: The local evaluations reviewed by the ED team did not provide analysis of the data generated and did not include recommendations for improvement. Citation: 20 U.S.C. 6381d(15), Section 1235(15) of ESEA, requires that each program provide for an independent evaluation of the program to be used for program improvement. Further Action Required: IDE must ensure that local programs improve the quality of the local evaluations, which should include an analysis of the data generated by the project and recommendations for improvement.

Area: Instructional Support
Critical Element 2.1 – State Use of Funds for Technical Assistance Recommendation: IDE’s technical assistance efforts do not appear to be tailored to the needs of each individual local project. ED recommends that IDE’s technical assistance efforts be targeted on areas identified for improvement through the State performance indicators during monitoring, or identified by local evaluators in the local evaluation reports. Critical Element 2.5 – Flexible Scheduling Commendation: The IDE has encouraged (and the program site visited demonstrated) flexibility in scheduling to accommodate various parents’ schedules, and removing

obstacles by providing necessary services such as childcare and transportation and outreach into the community. Critical Element 2.13 – Provision of Home-Based Instruction Commendation: The program visited demonstrated its focus on literacy and outreach to the families in the community participating in its Even Start program through the successful implementation of La Familia Inventory in conjunction with such activities as literacy book bags. Critical Element 2.16 and 2.18 – Use of Scientifically Based Reading Research and Reading-Readiness Activities are based on Scientifically Based Research Finding: The local Even Start project in Iowa City did not include a coherent instructional approach to teaching reading readiness skills in the early childhood component of the family literacy program. Also, based on materials reviewed during the interviews with project staff in Iowa City, the ED team found that instructional services did not appear to be based on scientifically based reading research. Citation: 20 U.S.C. 6381d(10), Section 1235(10) of ESEA, requires that each program use instructional programs based on scientifically based reading research for children and adults, to extent that the research is available. 20 U.S.C. 6381d(12), Section 1235(12) of ESEA, requires that each program include reading-readiness activities for preschool children based on scientifically based reading research, to the extent available, to ensure that children enter school ready to learn to read. 20 U.S.C. 6368(6), Section 1208(6) of ESEA, defines “scientifically based reading research” as used in the Even Start statute (20 U.S.C. 6381a(e)(4), Section 1231a(e)(4) of ESEA.) Further Action Required: Local projects must use the applicable statutory definition of “scientifically based reading research” to ensure that instructional activities and services are based on scientific research. The State coordinator should provide training in this area for local project staff. Critical Element 2.17 – Attendance and Retention Commendation: The program visited credits its participation rate to its outreach efforts to the families in the community, its flexibility to accommodate schedules and offering support services such as providing daycare.

Critical Element 3.4 – Timely and Meaningful Consultation and Provision of Equitable Services to Private School Children Finding: The IDE is not ensuring that the local programs provide for the equitable participation of students enrolled in non-public schools. Citation: 20 U.S.C. 7881 - 7886, Sections 9501 - 9506 of ESEA, require recipients of Federal funds to provide eligible school-age children who are enrolled in private elementary and secondary schools, and their teachers or other educational personnel, educational services and benefits under those programs on an equitable basis. Eligible entities must provide the equitable services after timely and meaningful consultation with the appropriate private school officials. Further Action Required: The IDE must ensure that all Even Start projects meaningfully consult with private school officials in order to provide Even Start services and benefits to eligible private school students and their teachers or other educational personnel on an equitable basis.